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VINCENT ENGINEERING COMPANY v. COMMISSIONER

Docket No. 15059-92.

66 T.C.M. 791 (1993)

T.C. Memo. 1993-435

Vincent Engineering Company v. Commissioner.

United States Tax Court.

Filed September 20, 1993.

Attorney(s) appearing for the Case

Michelle K. Loesch, for the respondent.

Memorandum Opinion

FAY, Judge:

This case was heard by Special Trial Judge James M. Gussis pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183. All section references are to the Internal Revenue Code, as amended. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

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